Governance

PROCEDURES FOR THE MANAGEMENT OF INSIDE INFORMATION AND THE KEEPING OF THE INSIDER REGISTER

The Company has adopted a Procedure for the management of Inside Information and the keeping of the Insider Register in compliance with the provisions of Consob guidelines no. 1/2017, regarding "Management of Inside Information", as well as art. 1, Recommendation 1, letter f) of the Corporate Governance Code.

The Procedure for the management of Inside Information and the keeping of the Insider Register has the objective of ensuring compliance with the confidentiality obligations established by legal provisions, monitoring access to and circulation of information which is or could become inside information and guaranteeing a communication of the same to the public according to criteria of transparency, timeliness and non-selectivity, in compliance with the legal and regulatory provisions in force, as well as regulating the methods of keeping and updating the register of people who have access to privileged information in carrying out certain tasks and with which there is a professional collaboration relationship (Insider Register).

INTERNAL DEALING

The Company has adopted an Internal Dealing Procedure in compliance with the provisions of Article 19 of Regulation (EU) No. 596/2014 on market abuse ("Market Abuse Regulation" or "MAR") and the Delegated Regulation (EU ) 2016/522.

The Internal Dealing Procedure is aimed at regulating with binding effectiveness the information flows inherent to the so-called Relevant Transactions, i.e. transactions pursuant to art. 19, par. 1 of MAR, carried out by Internal Dealing Parties for any reason, on the stock exchange or off-exchange, concerning:

• shares or debt instruments of the Company;
• derivative instruments;
• financial instruments linked to them, as identified pursuant to article 3, par. 2, letter. b) of Regulation (EU) n.596/2014.

RELATED PARTY TRANSACTIONS

The Company has adopted a Procedure for the regulation of Transactions with Related Parties, pursuant to article 2391-bis of the Civil Code and the Consob Regulation on Transactions with Related Parties (Consob resolution no. 17221 of 12 March 2010).

The Procedure for the regulation of Transactions with Related Parties has the objective of identifying the principles to which GHC complies in order to ensure the transparency and substantial and procedural correctness of the Transactions with Related Parties carried out by the same, directly or through the Subsidiary Companies.